Case 1:04-cv-01823-PSF-BNB
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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1823-PSF-BNB GERALD M. HAASE, M.D., Plaintiff, v. JEFFERSON PILOT FINANCIAL INSURANCE COMPANY, Defendant.
DEFENDANT'S UNOPPOSED MOTION TO MODIFY SCHEDULING ORDER
Defendant Jefferson Pilot Financial Insurance Company, by and through its attorneys, Hall and Evans, LLC, herewith submits this Defendant's Unopposed Motion to Modify the Scheduling Order. As grounds therefore, Defendant asserts: 1. By Minute Order of April 16, 2005, the Court scheduled the Pretrial
conference in this matter for January 18, 2006 and adjusted several scheduling deadlines issues. A further brief extension of time is necessary to complete certain activities as follows: a. Expert Witness Disclosures: The Plaintiff shall designate all experts
and provide opposing counsel with all information specified in Fed. R. Civ. P. 26(a)(2) on or before August 19, 2005;
Case 1:04-cv-01823-PSF-BNB
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b.
The Defendant shall designate all experts and provide opposing
counsel with all information specified in Fed. R.Civ. P. 26(a)(2) on or before September 19, 2005; c. The parties shall designate all experts and provide opposing counsel
with all information specified in Fed. R. Civ. P. 26(a)(2) on or before October 3, 2005l d. e. 2. Discovery Cutoff: November 3, 2005; Dispositive Motion Deadline: December 1, 2005.
The parties need this additional time to complete these activities and to
continue their efforts to negotiate a resolution of this matter. 3. Pursuant to D.C.COLO.L.CivR 7.1(A) counsel for Defendant conferred
with counsel for Plaintiff prior to filing this Motion. Plaintiff's counsel indicates he does not oppose this motion and stipulates that no party will be prejudiced by the extensions requested. 4. Pursuant to D.C.COLO.L.CivR.6.1(D), undersigned counsel is serving a
copy of this Motion on his client as indicated in the attached Certificate of Mailing. 5. The Pretrial Conference is set for January 18, 2006 need not be adjusted
if the requested extensions are acceptable to the Court. WHEREFORE, for the reasons stated above, Defendant Jefferson Pilot Financial Insurance Company respectfully requests that deadlines be modified as described herein for the designation of experts, discovery cutoff and filing of dispositive motions and for such other and further relief as this Court deems appropriate.
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Case 1:04-cv-01823-PSF-BNB
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DATED this 1st day of July, 2005. RESPECTFULLY SUBMITTED,
/s Kevin E. O'Brien Kevin E. O'Brien HALL AND EVANS, LLC 1125 17th Street, Suite 600 (DC BOX 5) Denver, CO 80202 303/628-3300 303/628-3368 [email protected] ATTORNEYS FOR DEFENDANT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 1st day of July, 2005, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following addressees: Steven Taffet, Esq. Taffet Law, P.C. 2305 Broadway Boulder, CO 80304 E:mail: [email protected] Stephanie T. Farrabow, Esq. (by U.S. mail) Assistant Vice President & Assoc. Counsel Jefferson Pilot Financial Insurance Co. PO Box 21008 Greensboro, NC 27420 /s Juanita P. Kursevich, Secretary Kevin E. O'Brien HALL AND EVANS, LLC 1125 17th Street, Suite 600 (DC BOX 5) Denver, CO 80202 303/628-3300 303/628-3368 [email protected] ATTORNEYS FOR DEFENDANT
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